In re the Civil Commitment of Navratil
2011 Minn. App. LEXIS 71
| Minn. Ct. App. | 2011Background
- Navratil challenged indeterminate civil commitment as an SDP, arguing the district court erred in treating him as an SDP and in ordering indeterminate commitment after evidence showed no treatment during the initial commitment.
- Navratil had a lengthy juvenile/adult history of sexual offenses and antisocial conduct beginning in adolescence, with multiple treatment failures and parole violations.
Two court-appointed psychologists, Dr. Hoberman and Dr. Alberg, evaluated Navratil; Hoberman favored SDP/SPP findings, while Alberg disputed both.
- The district court found Navratil met SDP criteria and ordered indeterminate commitment to MSOP; MSOP later submitted a report reaffirming SDP criteria.
- Navratil challenged that his initial commitment lacked treatment and argued due process concerns; the court held treatment availability outside the commitment process and continued review allowed indeterminate commitment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Navratil meets SDP criteria. | Navratil argues no clear evidence of disorder/likelihood to reoffend. | Court-appointed experts diagnosed a mixed personality disorder and paraphilia, with high likelihood of reoffending. | No error; clear and convincing evidence supports SDP designation. |
| Whether indeterminate commitment was proper despite no initial treatment. | Due process requires treatment during initial period; lack of treatment invalidates indeterminate commitment. | Treatment availability is outside commitment process; indeterminate commitment allowed if criteria persist. | No error; indeterminate commitment properly ordered. |
Key Cases Cited
- In re Commitment of Jackson, 658 N.W.2d 219 (Minn.App. 2003) (standard of review for SDP commitment findings)
- In re Commitment of Ramey, 648 N.W.2d 260 (Minn.App. 2002) (review of credibility and evidence in commitment cases)
- In re Blodgett, 510 N.W.2d 910 (Minn. 1994) (treatment rights and standards in civil commitment)
- In re Linehan, 557 N.W.2d 171 (Minn. 1996) ( Linehan factors for predicting dangerousness in SDP cases)
- In re Pope, 351 N.W.2d 682 (Minn.App. 1984) (treatment issues outside commitment process)
- In re Travis, 767 N.W.2d 52 (Minn.App. 2009) (avenues to challenge treatment adequacy outside commitment)